Feb

HMRC Investigation into £9million Property118 ‘Incorporation Relief’ Claim

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In June 2020 HMRC opened an investigation into a £9 million ‘incorporation relief’ claim made by a Property118 client who used the Beneficial Interest Company Transfer structure “BICT” to substantially incorporate their property rental business.

The HMRC manual states:

“TCGA92/S162 applies where a person other than a company transfers a business as a going concern with the whole of its assets (or the whole of its assets other than cash) to a company wholly or partly in exchange for shares.

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